MIPS Survival Guide – What You Need To Know Before It’s Too Late

The “Who, What, When, Where, Why, and How” of MIPS can be confusing.

MIPS combines several incentive reporting programs into one. The “Who, What, When, Where, Why, and How” of MIPS can be confusing.

The good news: it’s not too late to gather information and prepare for MIPS! In fact, you have time to collect enough performance data to sufficiently report for a positive payment adjustment.

Here is a summary of important information and reliable MIPS resources, as well as a checklist for what you need to do to get ready.

Who: MIPS Eligibility

You are eligible for MIPS if you bill Medicare more than $30,000 in Part B allowed charges a year and provide care for more than 100 Medicare patients a year.

If you are already in an Advanced Alternative Payment Model (APM) such as an MSSP ACO, you will most likely complete reporting through the APM. However; there are exceptions to this based on payment and patient thresholds.

If you are not meeting the requirements of MIPS through your participation in an APM, you may report as an individual or as part of a group. An individual is one NPI associated with one TIN. A group is two or more NPI’s associated with one TIN.

Groups of 25+ providers had the option of registering by June 30, 2017, to report by a submission method called a Web Interface and/or CAHPS for MIPS.

There are different submission methods and reporting periods (for example, groups of 25+ who registered will report for the entire 2017 calendar year) depending on if you report as an individual or as a group. This site provides more helpful information: https://qpp.cms.gov/mips/individual-or-group-participation

What: MIPS Scoring

MIPS reimburses providers based on a scoring system that compares the quality and cost of care to other providers. MIPS combines and replaces the three programs of PQRS, EHR Meaningful Use, and the Value-Based Modifier, and adds a new category called Clinical Practice Improvement Activities.

You can report for a full year for the same measures listed above in #2.

It’s important to remember that the time period for which you are reporting (90 days or 1 full year) does not determine the payment adjustment. The payment adjustment is determined by your scores, so strategically select the time frame that maximizes your ability to accurately report for the best scores.

When: Performance Period Timeline

The MIPS timeline includes important milestones to keep in mind. These milestones are the performance periods, reporting deadlines, and payment adjustment stages.

The first MIPS performance period is January 1, 2017 through the end of the year. You can select a 90-day period for which to report, or report for the entire year (if you’re going for a positive adjustment).

You can begin submitting for MIPS on January 1, 2018. The reporting deadline for MIPS is March 31, 2018.

The first payment adjustments based on performance go into effect on January 1, 2019.

The MIPS adjustment timeline incrementally increases the amount of positive or negative adjustments that will be applied to your reimbursements. For example, the 2017 performance year, with reporting due by March, 2018, determines the payment adjustment for 2019:

Performance Period

Reporting Deadline

Adjustment Year

Positive or Negative Adjustment

CY 2017

March 31, 2018

2019

+/- 4%

CY 2018

March, 2019

2020

+/- 5%

CY 2019

March, 2020

2021

+/- 7%

CY 2020

March, 2021

2022

+/- 9%

Where: Options and Methods of Submission

Where to report MIPS depends on if you are submitting as an individual or as a group. To further complicate your choices, the method of submission determines the quality measures from which you can choose and the benchmarks for each of these measures. For example, there are different measures and benchmarks for reporting by claims than for reporting by a MIPS registry.

The table below shows the options for the method(s) of submission for reporting as an individual or as a group.

Report as an Individual

(some options vary depending on performance category)

Report as a Group

(some options vary depending on performance category)

Qualified Clinical Data Registry (QCDR)

Qualified Clinical Data Registry (QCDR)

Qualified Registry

Qualified Registry

Electronic Health Record (EHR)

Electronic Health Record (EHR)

Claims

Claims

Attestation

Attestation

CAHPS for MIPS Survey (only available to groups with 2 or more eligible clinicians)

CMS Web Interface (only available to groups with 25 or more eligible clinicians)

Why: Reimbursement and Bonuses

An eligible MIPS provider could have their reimbursement revised upward as much as 4 percent ($400 per $10,000 of Part B revenue) in 2019. A provider who doesn’t report anything for MIPS this year (by March 31, 2018) would see an automatic 4 percent downward adjustment in 2019. These adjustments scale up +/- 9 percent by 2022.

There is more money at stake in the form of bonuses; CMS has set aside $500 million for each year between 2019 and 2024 for those who perform exceptionally well. The bonus amounts range from 0.5-10 percent depending on the provider’s score. In total, there is a potential downward adjustment of 4 percent of reimbursement in 2019, and a maximum of 14 percent upward for providers with exceptional performance.

How: MIPS Survival Guide Checklist

Decide if you’re going to report the minimum measures to avoid the penalty, or if you’d like to go for a positive payment adjustment.

Determine if you will be reporting MIPS as an individual, a group, or meeting the requirements through an APM. By this time, you should have received a letter from CMS explaining your MIPS status.

Select a reporting timeframe (90 days or the full calendar year) based on the requirements of the submission method you are using.

Select the measures for each of the categories of Quality, Improvement Activities, and Advancing Care Information that will provide you with the highest score. It is important to make sure you are selecting measures that are allowed based on the submission method you will be using.

Review the benchmarks associated with each of the measures you selected.